giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL
DEFENDANT TO ANSWER DEPOSITION QUESTIONS
Plaintiff Virginia Giuffre, by …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL
DEFENDANT TO ANSWER DEPOSITION QUESTIONS
Plaintiff Virginia Giuffre, by …
giuffre-maxwell
1320-6
10 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL
DEFENDANT TO ANSWER DEPOSITION QUESTIONS
Plaintiff Virginia Giuffre, by …
DataSet-10
EFTA01655686
18 pg
…Trump Appoints Former Secret Service Agent Dan Bongino as FBI Deputy Director,
Prompting Controversy Over Past Criticisms
• Sen. Blackburn Requests Unredacted Epstein Files, Director Patel Vows Cooperation as AG Bondi
Faces Bipartisan Pressure
• Continued Reporting: Director Patel to Lead Both…
DataSet-9
EFTA00095721
2 pg
…the FBI, and any other federal and state investigative agencies.
c. Unredacted copies of all emails and other correspondence between the
government and Mr. Epstein's attorneys concerning the negotiation of the
NPA, previously produced by the government on August…
DataSet-9
EFTA00091641
3 pg
…Program Statement,
Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392.
13.An unredacted copy of SDNY 7551.
14.An unredacted copy of SDNY 883.
15. SHU Watch Call Logs from August 9, 2019 and August 10…
DataSet-9
EFTA00722736
37 pg
…No.
5, in redacted form. An unredacted copy of the responses will be provided to the court upon the
court's request and/or in camera. In particular, the response to interrogatory number 5 states that
Jane Doe numbers 2…
DataSet-9
EFTA00091633
3 pg
…Program Statement,
Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392.
13.An unredacted copy of SDNY 7551.
14.An unredacted copy of SDNY 883.
15. SHU Watch Call Logs from August 9, 2019 and August 10…
DataSet-9
EFTA00099413
3 pg
…Program Statement,
Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392.
13.An unredacted copy of SDNY 7551.
14.An unredacted copy of SDNY 883.
15. SHU Watch Call Logs from August 9, 2019 and August 10…
DataSet-9
EFTA00209597
3 pg
…Brad:
> Good morning. I am writing to ask if you have any objection to a motion for a short extension of time to
comply with Judge Marra's order requiring us to file unredacted pleadings. Some of those have…
DataSet-9
EFTA00104832
6 pg
…given the protective order. Can you produce unredacted copies?
Thanks,
Chris
Christian Everdell
COHEN & GRESSER LLP
New York NY 10022
I view bio
worw.cohengresser.com
New York I Seoul I Paris I Washington DC I London
CONFIDENTIALITY NOTICE: The…
DataSet-9
EFTA00074697
6 pg
…There is no reason why the
documents need to be redacted, given the protective order. Can you produce unredacted copies?
Thanks,
Chris
Christian Everdell
COHEN & GRESSER LLP
NewY rk. NY 10022
view bio
www.cohengresser.com
New York I Seoul…
DataSet-9
EFTA00039985
4 pg
…intend the restriction on disclosure to be permanent.
I note also that, if we receive a court order (including a court-ordered subpoena) for the unredacted file, we will notify
you so that you can seek to preserve any investigative…
dnc-emails
Email
…crossword puzzles. The litigation ran on for five years, and during that time we had to petition the court to compel Trump to hand over unredacted versions of the tax returns -- which he ultimately did." [Timothy O'Brien, Bloomberg, 5…
dnc-emails
Email
…crossword puzzles. The litigation ran on for five years, and during that time we had to petition the court to compel Trump to hand over unredacted versions of the tax returns -- which he ultimately did." [Timothy O'Brien, Bloomberg, 5…
DataSet-10
EFTA01451661
1 pg
…provided that the terms of any such transaction are no less favourable to
the Fund than could be obtained in arm's length negotiations with unrelated third Persons
for similar transactions and shall be disclosed to the Advisory Committee annually)…
DataSet-10
EFTA01376296
1 pg
…Investment Manager
and/or one or more of its Affiliates are expected to purchase approximately $2.2 million of the Subordinated Notes.
Such Subordinated Notes may be transferred to related or unrelated parties at any time after the Closing Date…
DataSet-10
EFTA01365549
1 pg
…Investment Manager
and/or one or more of its Affiliates are expected to purchase approximately $2.2 million of the Subordinated Notes.
Such Subordinated Notes may be transferred to related or unrelated parties at any time after the Closing Date…
DataSet-9
EFTA00074322
7 pg
…Cc:
Subject: Re: David Rodgers Subpoena
How long do you guys anticipate going on Friday? I had something unrelated come up in the early afternoon. If you think
we're going to go for more than a couple of hours…
DataSet-9
EFTA00164295
4 pg
…is a possibility for
NY to get zero questions for the duration of the chat. There is a likelihood the Twitter page will get a lot of
bizarre questions unrelated to crime victim rights, in which case OPA vets those…